Audit of NRCan's Nuclear Energy Policy Activities

Presented to the Departmental Audit Committee (DAC)
April 8, 2021

TABLE OF CONTENTS

• EXECUTIVE SUMMARY
  • Introduction
  • Strengths
  • Areas for Improvement
  • Internal Audit Conclusion and Opinion
  • Statement of Conformance
  • INTRODUCTION
    • Audit Purpose and Objectives
    • Audit Considerations
    • Scope
    • Approach and Methodology
    • Criteria
  • FINDINGS AND RECOMMENDATIONS
    • Governance and Engagement Processes
    • Compliance with legislative and policy requirements
    • Reporting and Human Resource processes
  • APPENDIX A – AUDIT CRITERIA

  Executive Summary

  Introduction

  Nuclear power is a non-carbon emitting source of energy that makes up roughly 16% of Canada’s energy supply and is seen as a significant contributor to the country’s climate change mitigation efforts. According to the International Atomic Energy Agency (IAEA), Canada is well-regarded and considered a global leader in developing safety and regulatory standards, as well as in the research and development of new nuclear technologies.

  Working with the provinces, Natural Resources Canada (NRCan) is responsible for developing Canadian government policy to ensure the sustainable development and responsible use of nuclear energy throughout the country. NRCan also fulfils certain responsibilities related to key legislative documents pertaining to nuclear energy on behalf of the federal government.

  Within NRCan’s Low Carbon Energy Sector (LCES), the Electricity Resources Branch (ERB) supports the Department with its role related to nuclear energy through two of its Divisions: the Nuclear Energy Division (NED) and the Uranium and Radioactive Waste Division (URWD). In addition to NRCan, there are two other organizations, which report through the Minister of Natural Resources to the Parliament of Canada, that play key roles in Canada’s nuclear energy: the Canadian Nuclear Safety Commission (CNSC) and the Atomic Energy of Canada Limited (AECL). 

  The objective of the audit was to assess the adequacy of governance and the effectiveness of NRCan’s management processes related to nuclear energy policy activities.  

  This Audit of NRCan’s Nuclear Energy Policy Activities was included in the 2019-2024 Integrated Audit and Evaluation Plan, approved by the Deputy Minister on May 14, 2019. 

  Strengths

  There are governance and engagement processes in place to enable the Department to develop nuclear energy policy and fulfil its duties under relevant legislation. Available documentation on roles and responsibilities of the NED and the URWD is clear, well-understood, and aligned with strategic priorities. There are also processes in place to facilitate engagement and collaboration with key partners and stakeholders. In addition, mechanisms are in place to support NRCan in fulfilling its legislative requirements. Current reporting processes also allow for timely and informed management decision making. Furthermore, resource-planning processes have been established to support the Department’s nuclear energy policy activities.

  Areas for Improvement

  There are opportunities to improve the documentation of both Divisions’ roles and responsibilities to ensure the content is up-to-date, complete, and reflects the relationships with key partners and stakeholders. Although there are mechanisms and tools that are leveraged to ensure compliance with legislative requirements, there is an opportunity for both the NED and the URWD to develop and implement internal standard operating procedures (SOPs) to ensure continued compliance with, and a regular review of, relevant legislation and policy suites. In addition, in order to enhance the strength of current HR planning processes, the URWD and the NED have an opportunity to consider long-term staffing requirements and succession planning objectives.

  Internal Audit Conclusion and Opinion

  Overall, adequate governance and effective management processes related to nuclear energy policy activities were found to be in place; however, there are opportunities to improve these processes to better support the Department in fulfilling its legislative requirements.

  Statement of Conformance

  In my professional judgement as Chief Audit and Evaluation Executive, the audit conforms with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and the Government of Canada’s Policy on Internal Audit, as supported by the results of the Quality Assurance and Improvement Program.

  Michel Gould, MBA, CPA, CIA
  Chief Audit and Evaluation Executive
  April 8, 2021

  ACKNOWLEDGEMENTS

  The audit team would like to thank those individuals who contributed to this project and, particularly employees who provided insights and comments as part of this audit.

  INTRODUCTION

  Nuclear power is a non-carbon emitting source of energy that makes up roughly 16% of Canada’s energy supply and is seen as a significant contributor to the country’s climate change mitigation efforts. According to the International Atomic Energy Agency (IAEA), Canada is well-regarded and is considered a global leader in developing safety and regulatory standards, as well as in the research and development of new nuclear technologies.

  
  Source: Canadian Nuclear Safety Commission:
  Annual Report 2017-18
  (pdf, 4.78 Mb)

  Transcript

  This image depicts the Nuclear Fuel Cycle developed by the Canadian Nuclear Safety Commission (CNSC). The first step of the cycle is Mining-Uranium Ore; the second step is Milling-Yellowcake; the third step is Processing-Nuclear Fuel; the fourth step is Reactors-Fuel Bundle; and the fifth step is Waste-Dry Storage Container.

  Working with the provinces, Natural Resources Canada (NRCan) is responsible for developing Canadian government policy to ensure the sustainable development and responsible use of nuclear energy throughout the country. NRCan also fulfils certain responsibilities related to key legislative documents pertaining to nuclear energy on behalf of the federal government. These include responsibilities under the Nuclear Fuel Waste Act, which aims to ensure radioactive waste is controlled and stored in a safe manner, and the Nuclear Liability and Compensation Act, which has civil liability, compensation and other provisions, in the event of a nuclear incident resulting in damage or injury.

  Within NRCan’s Low Carbon Energy Sector (LCES), the Electricity Resources Branch (ERB) supports the Department with its role related to nuclear energy through two of its Divisions: the Nuclear Energy Division (NED) and the Uranium and Radioactive Waste Division (URWD). Together, the NED and URWD enable NRCan to develop federal policies and legislation on nuclear matters, and to provide expert technical, policy, and economic advice to the Minister on issues affecting all elements of the nuclear fuel cycle.

  In addition to NRCan, there are two other organizations, which report through the Minister of Natural Resources to the Parliament of Canada, that play key roles in Canada’s nuclear energy: the Canadian Nuclear Safety Commission (CNSC) and Atomic Energy of Canada Limited (AECL). The CNSC is an independent agency of the Government of Canada. Its mandate is to regulate the use of nuclear energy and materials to protect health, safety, security and the environment. AECL is a Crown Corporation established to develop peaceful applications of nuclear energy. Its mandate is to fulfill the Government’s waste and decommissioning responsibilities and to provide nuclear expertise to support federal roles and responsibilities. AECL’s Nuclear Laboratories are now being operated by Canadian Nuclear Laboratories Ltd. (CNL). In addition to the aforementioned partners, NRCan indirectly supports a number of key stakeholders through its policy and advisory functions. This includes organizations with responsibilities spanning across the nuclear fuel cycle, as well as the general public.

  This Audit of NRCan’s Nuclear Energy Policy Activities was included in the 2019-2024 Integrated Audit and Evaluation Plan, approved by the Deputy Minister on May 14, 2019.

  Audit Purpose and Objectives

  The objective of the audit was to assess the adequacy of governance and the effectiveness of NRCan’s management processes related to nuclear energy policy activities.

  Specifically, the audit assessed whether:

  • Adequate governance and effective engagement processes are in place  to enable the Department to develop nuclear energy policy and to fulfil its duties under relevant legislation; 
  • Effective management processes are in place to ensure compliance with relevant nuclear energy policies and legislation; and
  • Effective resource planning processes are in place to support the Department’s nuclear energy policy activities.

  Audit Considerations

  A risk-based approach was used in establishing the objectives, scope, and approach for this audit engagement. A summary of the key underlying potential risks that could impact the effectiveness of NRCan’s nuclear energy policy activities include: 

  • Adequate governance processes are necessary to enable the development and implementation of nuclear energy policy, including clearly defined roles and responsibilities as well as effective processes that facilitate the fostering of positive relationships with key partners and stakeholders.
  • Effective management processes are required to ensure compliance with the Nuclear Safety and Control Act, the Nuclear Fuel Waste Act, the Nuclear Liability and Compensation Act, the Nuclear Energy Act, and key policies. 
  • Effective human resource planning is necessary to ensure that the Department’s nuclear energy activities are well-supported.

  Scope

  The scope of the audit focused on the Department’s nuclear energy policy activities, including NRCan’s roles and responsibilities, its collaboration with external partners (e.g. other government departments, CNSC, AECL, CNL, provinces, industry groups, and international partners), as well as processes that support NRCan in performing its duties. The audit focused on the period beginning April 1, 2018, and ending April 1, 2020, to examine the most recent activities.

  The audit considered the results of NRCan’s 2018 Audit of International Activities that relate to the Department’s internal processes for coordinating and supporting international activities, including international travel, in order to avoid duplication of work performed in these areas.

  In addition, the audit took into account the results of the 2019 IAEA’s Emergency Preparedness Review mission, which examined NRCan’s preparedness for nuclear-related emergencies, as well as the 2019 IAEA’s Integrated Regulatory Review Services mission, which reviewed Canada’s Radioactive Waste Policy Framework.

  Approach and Methodology

  The approach and methodology used in this audit followed the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditingand the Treasury Board Policy on Internal Audit. These standards require that the audit be planned and performed in such a way as to obtain reasonable assurance that audit objectives are achieved. The audit included tests considered necessary to provide such assurance. Internal auditors performed the audit with independence and objectivity as defined by the IIA Standards.

  The audit included the following key tasks:

  • Interviews with key personnel with responsibilities surrounding NRCan’s nuclear energy activities;
  • Review of select documents and business processes; and
  • Testing of the Department’s compliance with key nuclear policies and legislation.

  The conduct phase of this audit was substantially completed in December 2020.

  Criteria

  Please refer to Appendix A for the detailed audit criteria. The criteria guided the audit fieldwork and formed the basis for the overall audit conclusion.

  Findings and Recommendations

  Governance and Engagement Processes

  Summary Finding

  Governance and engagement processes are in place to enable the Department to develop nuclear energy policy and fulfill its duties under the relevant legislation. Overall, available documentation on roles and responsibilities of the NED and the URWD is clear, well-understood, and aligned with strategic priorities; however, there are opportunities to improve the documentation of both Divisions’ roles and responsibilities to ensure the content is up-to-date, complete, and reflects the relationships with key partners and stakeholders. The audit team also found that processes are in place to facilitate engagement and collaboration with key partners and stakeholders.

  Supporting Observations 

  Adequate governance and effective engagement processes enable the Department to develop nuclear energy policy and fulfil its duties under relevant legislation. The audit sought to determine whether roles and responsibilities for nuclear energy policy activities are clearly documented, communicated, and are aligned with NRCan’s strategic priorities. Additionally, the audit examined whether effective processes were in place to facilitate engagement and collaboration with key partners and stakeholders.

  Roles and Responsibilities

  The NED develops federal policy on nuclear energy and provides advice on nuclear energy policy and legislation for the nuclear industry in Canada. Working closely with the NED, the URWD provides expert technical, policy, and economic information and advice to the Minister and the federal government on issues affecting the Canadian uranium industry and nuclear fuel cycle, the nuclear liability regime, and radioactive waste. The URWD also plays a corporate liaison role by providing support to the Minister in fulfilling responsibilities related to AECL. Both the NED and the URWD represent Canada on various nuclear energy issues in multinational forums. For example, the URWD supports the country in its contributions to the International Framework for Nuclear Energy Cooperation (IFNEC) as well as the IAEA International Expert Group on Nuclear Liability (INLEX). The NED represents Canada in the Nuclear Energy Agency (NEA) steering committee and leads the country’s delegation to attend the IAEA general conference every fall.

  Given the complex nature of the domestic and international nuclear landscapes, it is important that the roles and responsibilities of all major parties are clearly established and documented. This helps to ensure that the proper expertise is leveraged for decision-making and reduces the risk of duplicating efforts among affected parties. Through documentation reviews, the audit team determined that the URWD’s roles and responsibilities are documented in a number of presentation decks used internally to brief senior management. The most recent versions of these decks were developed in early 2019. They include overviews of the responsibilities of key partners and stakeholders, with an emphasis on the duties of the CNSC and the AECL relative to NRCan. Additionally, a separate document exists dedicated to outlining the roles and responsibilities of the URWD’s key partners and stakeholders.

  While the documented roles and responsibilities of the URWD are relatively thorough, the information is not all up-to-date. According to audit interviews, the documentation is only updated when there is a change in management. For example, presentation deck developed in January 2017 states that the Division is responsible for programs in the nuclear space, although interviews confirmed this responsibility is outdated and no longer valid.

  For the NED, the audit team found that their roles and responsibilities are mainly outlined in two documents: the 2017-18 Electricity Resources Branch placemat and the NED Mandate. The NED’s roles and responsibilities are also partially available through other sources, including working group Terms of Reference and correspondence with stakeholders. These documents provide limited detail on what the Division does, and are not currently up-to-date. The audit team also found that the roles and responsibilities of the NED relative to its relationships with key partners and stakeholders have not been documented; however, the audit noted there are compensating activities in place to inform key partners and stakeholders of their activities and how they can serve the Canadian nuclear industry. This includes regular emails to diverse stakeholder groups and through the Quarterly Nuclear Energy Sessions hosted by the NED. These avenues serve to enable NED’s role to be recognized and understood amongst nuclear stakeholders.

  Alignment with Strategic Priorities

  The audit team reviewed the following overarching sources that identify the Department’s nuclear strategic objectives and priorities: the 2019 Minister’s Mandate letter, the 2019-2020 Department Plan, the 2018-2019 Departmental Results Report, as well as the Minister’s Speech for the 2020 CAN’s Annual Conference. Nuclear energy policy activities fall under broader NRCan priorities and commitments such as clean power, sustainable resource development, and market access and competitiveness. The audit team compared the identified roles and responsibilities of the NED and URWD to these strategic priorities, to examine whether the Divisions’ regular operations support departmental objectives. The audit team found that the roles and responsibilities of the NED and the URWD are aligned with the strategic nuclear priorities for the Department as they are described in the aforementioned sources.

  Engagement Processes

  The NED and the URWD perform engagement and collaboration activities with key partners and stakeholders both domestically and internationally. They engage with other government departments and industry stakeholders (such as AECL, Nuclear Waste Management Organization, Nuclear Operators, etc.), as well as international forums and conferences.

  The audit team found that the URWD maintains an adequate record of its engagement events and activities as they occur and has also formalized its communication and collaboration activities in MOUs and legislative documents, where appropriate. For the NED, its various key partner and stakeholder engagement and collaboration processes were well documented. Notably, a stakeholder engagement chart as well as an international engagement chart keep a record of its key partners and stakeholders, and offer a concise description of how it engages with them. In addition, the NED and URWD maintain adequate records of collaboration and engagement events that take place. Available documentation fully captures the completed collaboration activities described by the NED and the URWD in support of fulfilling their roles and responsibilities.

  Furthermore, the audit team found that the nature of the NED and the URWD engagement and collaboration activities with key partners and stakeholders would enable NRCan to further its strategic objectives. The frequency and subject matter of these engagement activities ensure that regular interactions are taking place between NRCan and its stakeholders, which supports the NED and the URWD in maintaining effective working relationships with stakeholders and to fulfilling their roles and responsibilities.

  RISK AND IMPACT

  Without complete and up-to-date documented roles and responsibilities for the Department that reflect the relationships with key partners and stakeholders related to nuclear policy energy activities, there is a risk that inefficiencies may be created in fulfilling NRCan’s established roles and responsibilities under policy and legislative requirements. This risk may be elevated in times of employee and/or management turnover, when the continuity of activities is challenged, and adequate documentation of roles and responsibilities must be referenced to ensure compliance.

  Recommendation 

  Recommendation 1: It is recommended that the ADM of LCES establish a process to fully document and periodically update the roles and responsibilities of the NED and the URWD, including clear descriptions of the relationships with key partners and stakeholders.

  Management Response and Action Plan

  Management agrees with Recommendation #1

  • A Roles and Responsibilities document will be developed to ensure the roles and responsibilities of staff within NED and URWD are fully documented and periodically updated.
  • Supplemental tables will provide the most recent organizational structure for each Division, and identify the key roles and responsibilities of each position identified.
  • An additional table will be developed and periodically updated identifying key partners and stakeholders for each Division. The table will include descriptions of each partner and stakeholder, and identify key internal and external contact points.
  • Directors will review progress monthly with their staff until completion of the above tasks.

  Key Steps/Deliverables:

  1. Draft Roles and Responsibilities document
  2. Draft Supplementary Tables – Aggregation of data within Divisions
  3. Final Edited Draft Document – including Tables
  4. Director Approval
  5. DG Approval
  6. ADM Approval
  7. Submission to Audit and Evaluation Branch

  Position responsible:

  NED and URWD Directors will be responsible for the deliverables above for their respective Divisions. 

  Timing:

  1. Draft Roles and Responsibilities Document Text (Jun 25, 2021)
  2. Draft Supplementary Tables (June 25, 2021)
  3. Final Edited Draft Document – including Tables (July 30, 2021)
  4. Director Approval (Aug 20, 2021)
  5. DG Approval (Sep 3, 2021)
  6. ADM Approval (Sep 10, 2021)
  7. Submission to Audit and Evaluation Branch (Sep 30, 2021)
  8. Documents to be reviewed annually by Director of URWD and NED (ongoing).

  Compliance with legislative and policy requirements

  Summary Finding

  Overall, standard operating procedures (SOPs) are not in place to ensure compliance with relevant nuclear energy policies and legislation, including to review and assess legislative requirements, and follow up on perceived areas requiring changes/updates. However, there are alternate mechanisms in place to support NRCan in fulfilling its legislative requirements, and the audit team found that the Department complied with relevant legislative requirements within the scope period. There is an opportunity for the NED and the URWD to develop and implement SOPs to ensure continued compliance with, and the regular review of, relevant legislation and policy suites.

  Supporting Observations

  Effective processes enable the Department to ensure that it is compliant with relevant nuclear energy policies and legislation. The audit sought to determine whether processes have been established and documented to ensure that NRCan fulfills its legislative and operational requirements. Additionally, the audit examined whether effective processes were in place to review and assess legislative requirements, to inform the development of policy options.

  Processes and Compliance with Legislative Requirements

  The NED and the URWD support the Department in developing nuclear energy policy and to fulfill its duties under the following legislation/policy:

  • Nuclear Fuel Waste Act (NFWA)
  • Nuclear Liability and Compensation Act (NLCA)
  • Nuclear Energy Act (NEA)
  • Nuclear Safety and Control Act (NSCA)
  • Canada’s 1996 Policy Framework on Radioactive Waste (PFRW)

  The audit team found that, while internal SOPs have not been developed, NED and URWD leverage various mechanisms to ensure NRCan fulfills its legislative and operational requirements under these Acts and policies. The URWD leverages internally developed administrative documents/tools to ensure that requirements under the NFWA and NLCA are met. The NED’s supporting role with respect to the NSCA reduces its requirement to have formally documented processes, given that the Division acts in a policy advisory capacity only, and that the Act is administered by the CNSC. Similarly, the NEA is an authority-providing piece of legislation, providing the Department with the ability to undertake research and/or investigations as required, limiting the necessity for formalized internal processes. However, for the Acts/policies where NRCan plays an administrative role (NFWA, NLCA and PFRW), SOPs would enhance the ability to ensure operational, legislative, and policy requirements are met.

  The audit team reviewed the requirements under the above Acts and policies, and assessed whether NRCan met the relevant requirements within the audit scope period. They found that the Department is currently in compliance with requirements specified under these Acts; however, it was observed that many clauses under the NFWA and NLCA are not applicable at this time, resulting in a greater need to consider the development of SOPs to ensure that clauses not yet activated be adequately addressed, should they be triggered.

  Given that the Department mainly plays a policy advisory role for the NSCA and the NEA, and that these Acts do not have specific requirements for NRCan, the audit team did not assess direct compliance with these Acts. The PFRW contains high-level principles/obligations in NRCan’s areas of responsibility; however, it does not explicitly outline specific requirements for NRCan to adhere to, but rather provides a policy framework in which to operate. Therefore, the audit team did not assess compliance with the PFRW.

  Review of Relevant Acts/Policy

  The NED and the URWD do not have SOPs in place that describes how to assess and follow up on elements of legislative and policy documents in need of review. Reviews are predominately conducted on an as needed basis. When required to make legislative changes, both Divisions indicated that they follow Government of Canada/Central Agency guidance.

  The URWD leverages a variety of administrative tracking documents to ensure legislation is reviewed and assessed (where required), in order to inform potential changes. In addition, the audit team found that the URWD is currently reviewing the PFRW as a result of an international peer review (Integrated Regulatory Review Service – IRRS) by the International Atomic Energy Agency (IAEA). The IRRS report to Canada highlighted the requirement for potential improvements to the PFRW; it recommended that Canada should enhance the existing policy and establish the associated strategy for the PFRW. The audit team noted that the URWD has developed a work plan that describes the phased approach that will be undertaken by NRCan to address the IRRS recommendation, which includes support from the Nuclear Waste Management Organization, as well as cross-Canada consultations. The URWD has also developed a schedule for the planned development of the revised policy for nuclear waste management by identifying key tasks/activities that should be executed by NRCan as well as timelines/expected deadlines. The URWD’s review of the PFRW may subsequently result in the development of new nuclear-related policy tools.

  RISK AND IMPACT

  In the absence of internal SOPs, NRCan’s ability to monitor and track compliance and ensure periodic review of policy and legislative requirements may be inhibited. In the event that new legislative requirements are triggered, without adequate SOPs, NRCan may face challenges in ensuring that they are adequately addressed in a timely manner.

  Recommendation 

  Recommendation 2: It is recommended that the ADM of LCES develop standard operating procedures to:

  • enhance the ability to monitor compliance and track how NRCan fulfills current and future legislative and operational requirements under the relevant nuclear energy policies and Acts applicable to the Department; and
  • periodically review, assess, and update, where applicable, policies and Acts where NRCan has responsibilities, to ensure continued relevancy.

  Management Response and Action Plan

  Management agrees with Recommendation #2

  • SOPs will be developed to enhance the ability of NRCan (NED/URWD) to monitor compliance and track how it fulfills current and future legislative and operational requirements under the relevant nuclear energy policies and Acts applicable to the Department.
  • The SOPs will provide general guidance on review frequency and process, subject to the nature of the individual SOPs and their respective subject matter (e.g. legislative vs. legal agreement vs. policy).
  • The key SOPs identified below will be reviewed for relevancy and adequacy through a periodic refresh process at a frequency to be determined by management, to ensure they remain relevant and add value.

  Key SOPs:

  1. Nuclear Fuel and Waste Act
  2. Nuclear Liability and Compensation Act
  3. Non-Resident Ownership Policy for Uranium Mines
  4. Administration of Memoranda of Agreements and Understanding (e.g. Denison Mines, SK MOU, ON MOU)
  5. Administration of international treaty commitments (e.g. Convention on Supplementary Compensation for Nuclear Damage, Convention on Nuclear Safety, Joint Convention)
  6. Other operational functions (e.g. Emergency Management, NEA/IAEA Red Book).
  • In addition, the 1996 Canada Radioactive Waste Policy Framework, which is currently under review, will be subject to future periodic reviews at a set frequency to be determined by management.

  Position responsible:

  NED & URWD Directors will be responsible for the deliverables above for their respective Divisions. 

  Timing:

  1. First Draft SOPs (Jun 25, 2021)
  2. Final Edited Draft SOPs (July 30, 2021)
  3. Director Approval (Aug 20, 2021)
  4. DG Approval (Sept 3, 2021)
  5. ADM Approval (Sep 30, 2021)
  6. Submission to Audit and Evaluation Branch (Sep 30, 2021)

  Reporting and Human Resource processes

  Summary Finding

  There are reporting processes in place to allow for timely and informed management decision making as well as resource planning processes to support the Department’s nuclear energy policy activities. In order to enhance the strength of HR planning processes, the URWD and the NED have an opportunity to consider long-term staffing requirements and succession planning.

  Supporting Observations

  Effective reporting processes as well as resource planning processes should be in place to support the Department’s nuclear energy policy activities. The audit examined whether effective reporting processes are in place to allow for timely and informed management decision making. Additionally, the audit sought to determine whether resource planning processes are in place that consider current and future human resource requirements related to NRCan’s nuclear energy policy activities. According to commitments outlined within their Performance Management Agreements (PMAs), executives are expected to develop an HR plan, leveraging data analytics. A strong HR plan would incorporate short and long-term objectives, succession planning, and consider diversity, as suggested under the HR Planning – A Guide for Managers, available on the departmental intranet, The Source.

  The audit team also assessed whether employees with responsibilities related to NRCan’s nuclear energy policy activities are provided with the training, tools, and other resources necessary to fulfill their roles.

  Reporting

  The NED and the URWD perform various reporting activities in order to inform senior management of the nuclear policy activities at NRCan. The audit team found that formal and/or informal reporting processes were in place at all management levels. Priority items regarding nuclear activities under the Divisions’ mandate are discussed on a regular basis, including with the Director General of ERB, the Assistant Deputy Minister of LCES, and the Associate Deputy Minister.

  The audit also found that, overall, reporting within the URWD and the NED in terms of the content/information as well as the frequency is adequate. Therefore, there is sufficient communication between management levels on a regular basis to allow senior management to make informed decisions.

  Human Resource Processes

  The audit team found that NED leverages HR planning-related processes and documents, including weekly management meetings where staffing discussions occur. Available documentation focused on immediate and short-term HR requirements. For the URWD, the division has a draft HR plan in place that is up-to-date, but not yet finalized. The plan includes short-term considerations and succession planning, with a limited focus on long-term succession planning. Both NED and URWD indicated that they discuss diversity considerations as part of their HR planning processes.

  Frequency of reviewing HR needs varies depending on the structure of the plan. Many of the NED’s HR planning documents, such as the Staffing Actions Plan and the Salary Budget Plan, are reviewed and revised frequently, updated on an annual basis, and based on operational requirements; the NED also informed the audit team that they update their HR staffing plan on a weekly basis, proactively advise ERB’s DGO of any changes, and provide formal monthly updates to the DGO. The URWD recently developed its draft HR plan, which is subject to change depending on staffing needs and the Branch/Sector financial situation. In addition, the URWD provides HR forecast updates as requested by the DGO, and HR is also discussed during Director-DG bi-lateral meetings, which occur on a weekly basis. Both NED and URWD indicated that they leverage existing Branch/Sector staffing processes when looking to hire new employees.

  Going forward, there is an opportunity for NED and URWD to consider long-term staffing requirements and succession planning objectives as part of their HR planning processes to ensure that future HR needs, competencies, and overall priorities are sufficiently met. This will support the Divisions in delivering on their respective priorities as well as to ensure the diversity of their resources. They should also continue to reference and leverage HR planning taking place at the Branch/Sector level in determining their individual requirements. NED and URWD have indicated that they plan to consider long-term staffing requirements and succession planning needs in future HR planning exercises to ensure continuity of operations, including where subject matter expertise may be uniquely required.

  The audit team found that both NED and URWD develop individual training plans that are created through the Public Service Performance Management (PSPM) Application, and maintained through mid-year and annual discussions between staff and management. Generally, management indicated the training needs are being met, tools and resources are available for the Divisions to fulfill their respective roles and responsibilities, and that training opportunities provided to staff are based both on mandatory requirements and opportunities as they arise.

  APPENDIX A – Audit Criteria

  The criteria were developed primarily from key controls set out in the TBS Core Management Controls. The criteria guided the fieldwork and formed the basis for the overall audit conclusion.

  The objective of the audit was to assess the adequacy of governance and the effectiveness of NRCan’s management processes related to nuclear energy policy activities.  

  The following audit criteria were used to conduct the audit:

  Audit Sub-Objectives	Audit Criteria
  Sub-Objective 1: To determine whether adequate governance and effective engagement processes are in place to enable the Department to develop nuclear energy policy and fulfil its duties under relevant legislation.	1.1 Departmental roles and responsibilities for nuclear energy policy activities are clearly documented, communicated, and are aligned with NRCan’s strategic prioritiesp
  	1.2 Effective processes are in place to facilitate engagement and collaboration with key partners and stakeholders.
  Sub-Objective 2: To determine whether effective processes are in place to ensure compliance with relevant nuclear energy policies and legislation.	2.1 Effective processes have been established and documented to ensure that NRCan fulfills its legislative and operational requirements.
  	2.2 Effective processes are in place to review and assess legislative requirements, to inform the development of policy options.
  	2.3 Effective reporting processes are in place to allow for timely and informed management decision making.
  Sub-Objective 3: To determine whether effective resource planning processes are in place to support the Department’s nuclear energy policy activities.	3.1 Effective resource planning processes are in place that consider current and future human resource requirements related to NRCan’s nuclear energy policy activities.
  	3.2 Employees with responsibilities related to NRCan’s nuclear energy policy activities are provided with training, tools, and other resources necessary to fulfill their roles.